No. 14-14-00169-CV

In the Court of Appeals for the 

Fourteenth Court of Appeals District at Houston 

Kyle Tauch, Tranquility Apartments 

General Corporation and 

Tranquility Apartments, Ltd., 

 Appellants/Cross-Appellees, 

v.

Joel R. Scott, 

 Appellee/Cross-Appellant.

Appeal from the 80th Judicial District Court of Harris County, Texas 

Trial Court Cause No. 2011-21305 

Unopposed First Motion for Extension 

of Time to File Reply Brief of Cross-Appellant 

TO THE HONORABLE COURT OF APPEALS: 

 Appellee/Cross-Appellant, Joel R. Scott, respectfully files this Unopposed 

First Motion for Extension of Time to File his Reply Brief of Cross-Appellant. 

1. The present deadline for filing the reply brief is June 8, 2015. 

2. Appellee/Cross-Appellant seeks a two-week extension, until June 22, 

2015, in which to file his reply brief. 

ACCEPTED

14-14-00169-CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

6/8/2015 11:01:06 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 6/8/2015 11:01:06 AM CHRISTOPHER A. PRINE Clerk
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3. This is Appellee/Cross-Appellant’s first request for an extension of 

time to file the brief.

4. This motion is unopposed.

5. Appellee/Cross-Appellant needs the additional time to file his brief

with this Court for the following reasons:

Lead appellate counsel, Chad Flores, has been engaged in other litigation 

with imminent deadlines that have prevented him from completing the reply brief

before the deadline, including, but not limited to, the following:

 Assistance in preparation of a petitioners’ brief on the merits in No. 

14-0507, Ineos USA, LLC v. Elmgren, in the Supreme Court of Texas. 

The petitioners’ brief was filed May 22, 2015.

 Assistance in preparation of a petitioner’s brief on the merits in No. 

14-0894, Meritage Homes of Texas, L.L.C. v. Ruan, in the Supreme 

Court of Texas. The petitioner’s brief was filed on June 1, 2015.

 Preparation of a real party in interest’s brief on the merits in No. 

14-0804, In re Seneca Resources Corp., in the Supreme Court of 

Texas. The real party in interest’s brief on the merits is due to be filed 

on or before June 22, 2015.

 Assistance in preparation of a reply brief in No. 14-20717, Forum 

Subsea Rentals v. Elsharhawy, in the United States Court of Appeals 

for the Fifth Circuit. The appellants’ reply is due to be filed on or 

before June 22, 2015.

 Assistance in preparation of a petitioner’s reply in support of a 

petition for review in No. 14-0971, Clef Construction, Inc. v. CCV 

Holdings, LLC, in the Supreme Court of Texas. The petitioner’s reply 

is due to be filed on or before June 22, 2015.
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 Preparation of a brief of appellee in No. 01-15-232-CV, Nationwide 

Distribution Services, Inc. v. Jones, in the Court of Appeals for the 

First District of Texas. The brief of appellee is due to be filed on or 

before June 29, 2015.

 Preparation of responses to five motions for summary judgment in In 

re West Explosion Cases (City of West v. CF Industries Sales, LLC), 

in the 170th District Court of McLennan County. The responses are 

due to be filed on or before July 8, 2015.

6. This motion is not filed for the purpose of delay, but to allow counsel 

adequate time to prepare the cross-appellant’s reply brief.

PRAYER FOR RELIEF

For these reasons, Appellee/Cross-Appellant respectfully requests that this 

Court grant him an extension of time to file his reply brief until June 22, 2015.

Respectfully submitted,

BECK REDDEN LLP

By: /s/ Chad Flores

Chad Flores

State Bar No. 24059759

1221 McKinney, Suite 4500

Houston, Texas 77010

713.951.3700

713.951.3720 (Fax)

cflores@beckredden.com

Attorneys for Appellee/Cross-Appellant,

Joel R. Scott
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Certificate of Conference

I certify that I conferred with appellate counsel for Appellant, who does not 

oppose the requested extension.

/s/ Chad Flores

Chad Flores

Certificate of Service

A true and correct copy of the above and foregoing motion was properly 

forwarded to counsel of record for Appellant in accordance with Texas Rules of 

Appellate Procedure 9.5 by the e-file service provider on this the 8

th day of June, 

2015, addressed as follows:

Michele Barber Chimene

The Chimene Law Firm

15203 Newfield Bridge Lane

Sugar Land, TX 77498

michelec@airmail.net

Counsel for Appellants/Cross-Appellees Kyle Tauch, Tranquility Apartments

General Corporation and Tranquility Apartments, Ltd.

/s/ Chad Flores

Chad Flores